Tick the boxes is not enough: Leadership in food safety management in Australia

My friend Andrew Thomson writes in this piece for Hospital Health here in Australia:

COVID-19 has sharpened our focus on safety, with lockdown providing an opportunity to reflect on current approaches and where improvements to compliance policies and practices could be achieved.

Food safety management systems in Australia have largely not changed on the safety front. A one-size-fits-all approach to food safety management systems is widespread across the foodservice sector — a certain recipe for failure. All too familiar food safety problems persist at unacceptably high rates.

Leaders (at all levels) do not fully understand their food safety obligations — they are wanting a quick fix so they can tick the regulatory box.

Characteristically, a leader within an organisation will copy and paste another organisation’s food safety management system and make minimal changes; or they will download a template to assist them develop what they believe is a compliant system. This leader fills out a few text boxes here and there throughout the document, which is done in isolation of operational employee consultation and involvement. The newly created food safety management system completely lacks operational detail and bears no resemblance to site-specific operational and food law requirements.

Validating the system and developing robust verification mechanisms are poorly understood, and in many cases does not occur.

Production processes impacting on food safety are not fully understood by operational leaders and employees, or there is inconsistent understanding of the processes. If leaders and employees do not know how the food safety system works (or is supposed to work), how can they improve it?

There are significant shortcomings around resource allocation, including sub-par training — there is no genuine commitment to training, nor are there any accountability processes in place — this is just another example of ticking the box.

Food handling employees need to know:

what to do,

how to do it,

why it’s important, and

what corrective actions to take when required.

Corrective action is a critical food safety step that helps prevent a food safety incident from occurring.

The dated ‘compliance-based training’ and ‘mandatory online modules’ approach and refresher training has failed. New training and learning habits and practices will need to be created.

Implementation and meaningful review of food safety management systems rarely occur. An organisation must be able to demonstrate that it is complying with its food safety management system and conduct a regular review — a requirement of Australian food law.

A review is of critical importance as food production activities within the operation will change over time, such as when new equipment is purchased or changes are made to cooking methods.

The involvement of senior leadership is required in the review process, to provide an opportunity to examine business activity from a different perspective. Soft or inconsistent regulatory audits are simply not helpful and place the organisation and other stakeholders at risk, including the regulator. In many situations food safety management is not a priority and is not taken seriously, with a ‘she’ll be right’ approach, until there is a food safety incident or regulatory intervention. This can often lead to unwanted and negative (social) media attention.

Food safety colleague Dr Doug Powell explained that when there is an outbreak of foodborne illness many food operations will rely on a go-to soundbite, “Food safety is our top priority”.

For Dr Powell, a former professor of food safety for 17 years at the universities of Guelph and Kansas State, this sets up a mental incongruity: if food safety is your top priority, shouldn’t you show me?

The other common soundbite is, “We meet all government standards”.

With a changing regulatory landscape, advances in technology, and food products and ingredients travelling great distances, it is time for senior leadership and boards of directors to elevate the food safety conversation within their organisation.

Far too many foodservice operations are leaving brand protection to government inspectors or auditors — this is a bad idea.

Organisational leaders should commit themselves to achieving optimal industry standards in food safety management instead of aiming to meet minimum requirements. Leaders must be actively involved in celebrating team success and equally the reporting and development of risk-reduction strategies when a food safety issue arises. Leaders must hold every employee accountable for consistent adherence to recognised food law requirements and safety practices. Failing to respond to these matters leaves many organisations (and employees) vulnerable to a myriad of risks.

Are they judging jams? Blue-ribbon panel on the prevention of foodborne Cyclospora outbreaks

When someone says a blue-ribbon panel summarized results on the prevention of foodborne Cyclospora outbreaks, I think blue-ribbons is talking about jams or Holsteins at county fairs.

She was sick for weeks.

On June 12, 1996, Ontario’s chief medical officer, Dr. Richard Schabas, issued a public health advisory on the presumed link between consumption of California strawberries and an outbreak of diarrheal illness among some 40 people in the Metro Toronto area. The announcement followed a similar statement from the Department of Health and Human Services in Houston, Texas, who were investigating a cluster of 18 cases of Cyclospora illness among oil executives.

She was sick for weeks.

It’s the fog of outbreaks..

Like the fog my daughter played in last Sat. at the Gold Coast.

On June 12, 1996, Ontario’s chief medical officer, Dr. Richard Schabas, issued a public health advisory on the presumed link between consumption of California strawberries and an outbreak of diarrheal illness among some 40 people in the Metro Toronto area. The announcement followed a similar statement from the Department of Health and Human Services in Houston, Texas, who were investigating a cluster of 18 cases of Cyclospora illness among oil executives.

Dr. Schabas advised consumers to wash California berries “very carefully” before eating them, and recommended that people with compromised immune systems avoid them entirely. He also stated that Ontario strawberries, which were just beginning to be harvested, were safe for consumption. Almost immediately, people in Ontario stopped buying strawberries. Two supermarket chains took California berries off their shelves, in response to pressure from consumers. The market collapsed so thoroughly that newspapers reported truck drivers headed for Toronto with loads of berries being directed, by telephone, to other markets.

However, by June 20, 1996, discrepancies began to appear in the link between California strawberries and illness caused by the parasite, Cyclospora, even though the number of reported illnesses continued to increase across North America. Texas health officials strengthened their assertion that California strawberries were the cause of the outbreak, while scientists at the U.S. Centers for Disease Control and Prevention (CDC) and the Food and Drug Administration (FDA) said there were not yet ready to identify a food vehicle for the outbreak. On June 27, 1996, the New York City Health Department became the first in North America to publicly state that raspberries were also suspected in the outbreak of Cyclospora.

By July 18, 1996, the CDC declared that raspberries from Guatemala — which had been sprayed with pesticides mixed with water that could have been contaminated with human sewage containing Cyclospora — were the likely source of the Cyclospora outbreak, which ultimately sickened about 1,000 people across North America. Guatemalan health authorities and producers have vigorously refuted the charges. The California Strawberry Commission estimates it lost $15 million to $20 million in reduced strawberry sales.

Cyclospora cayetanensis is a recently characterised coccidian parasite; the first known cases of infection in humans were diagnosed in 1977. Before 1996, only three outbreaks of Cyclospora infection had been reported in the United States. Cyclospora is normally associated with warm, Latin American countries with poor sanitation.

One reason for the large amount of uncertainty in the 1996 Cyclospora outbreak is the lack of effective testing procedures for this organism. To date, Cyclospora oocysts have not been found on any strawberries, raspberries or other fruit, either from North America or Guatemala. That does not mean that cyclospora was absent; it means the tests are unreliable and somewhat meaningless. FDA, CDC and others are developing standardized methods for such testing and are currently evaluating their sensitivity.

The initial, and subsequent, links between Cyclospora and strawberries or raspberries were therefore based on epidemiology, a statistical association between consumption of a particular food and the onset of disease. For example, the Toronto outbreak was first identified because some 35 guests attending a May 11, 1996 wedding reception developed the same severe, intestinal illness, seven to 10 days after the wedding, and subsequently tested positive for cyclospora. Based on interviews with those stricken, health authorities in Toronto and Texas concluded that California strawberries were the most likely source. However, attempts to remember exactly what one ate two weeks earlier is an extremely difficult task; and larger foods, like strawberries, are recalled more frequently than smaller foods, like raspberries. Ontario strawberries were never implicated in the outbreak.

Once epidemiology identifies a probable link, health officials have to decide whether it makes sense to warn the public. In retrospect, the decision seems straightforward, but there are several possibilities that must be weighed at the time. If the Ontario Ministry of Health decided to warn people that eating imported strawberries might be connected to Cyclospora infection, two outcomes were possible: if it turned out that strawberries are implicated, the ministry has made a smart decision, warning people against something that could hurt them; if strawberries were not implicated, then the ministry has made a bad decision with the result that strawberry growers and sellers will lose money and people will stop eating something that is good for them. If the ministry decides not to warn people, another two outcomes are possible: if strawberries were implicated, then the ministry has made a bad decision and people may get a parasitic infection they would have avoided had they been given the information (lawsuits usually follow); if strawberries were definitely not implicated then nothing happens, the industry does not suffer and the ministry does not get in trouble for not telling people. Research is currently being undertaken to develop more rigorous, scientifically-tested guidelines for informing the public of uncertain risks.

But in Sarnia (Ontario, Canada) they got a lot of sick people who attended the Big Sisters of Sarnia-Lambton Chef’s Challenge on May 12, 2010.

Michael T. Osterholm, PhD, who has a lot of titles and once called me at 5 a.m. to tell me I was an asshole (maybe not the exact words, but the sentiment) and chair of the Holstein Blue-Ribbon Panel on the Prevention of Foodborne Cyclospora Outbreaks writes that the 1996 cyclosporiasis outbreak in the United States and Canada associated with the late spring harvest of imported Guatemalan-produced raspberries was an early warning to public health officials and the produce industry that the international sourcing of produce means that infectious agents once thought of as only causing traveler’s diarrhea could now infect at home. The public health investigation of the 1996 outbreak couldn’t identify how, when, where, or why the berries became contaminated with Cyclospora cayetanensis.

The investigation results were published in the New England Journal of Medicine in 1997. I was asked to write an editorial to accompany the investigation report.2 In my editorial, I noted the unknowns surrounding the C. cayetanensis contamination. The 1997 spring harvest of Guatemalan raspberries was allowed to be imported into both the United States and Canada—and again, a large outbreak of cyclosporiasis occurred. As in the 1996 outbreak, no source for the contamination of berries was found. Later in 1997, the Food and Drug Administration (FDA) prohibited the importation of future spring harvests of Guatemalan raspberries until a cause for the contamination could be demonstrated and corrective actions taken. While the FDA did not permit the 1998 importation of the raspberries into the United States, the berries continued to be available in Canada. Outbreaks linked to raspberries occurred in Ontario in May 1998. When the U.S. Centers for Disease Control and Prevention (CDC)-led investigative team published its 1997 outbreak findings in the Annals of Internal Medicine, 3 I was again asked to write an accompanying editorial.4 As I had done in my previous editorial, I highlighted how little we know about the factors associated with the transmission Cyclospora on produce and how to prevent it.

Unfortunately, the state of the art for preventing foodborne, produce-associated cyclosporiasis had changed little since the 1996 outbreak despite the relatively frequent occurrence of such outbreaks.

Thirty-two years after that first Guatemalan raspberry-associated outbreak — and a year after produce-associated cyclosporiasis outbreaks that were linked to U.S.-grown produce — we have taken a major step forward in our understanding of these outbreaks and how to prevent them. After Fresh Express produce was identified in one of the 2018 outbreaks, I was asked by the company leadership to bring together the best minds’ around all aspects of produceassociated cyclosporiasis. The goal was to establish a Blue-Ribbon Panel to summarize state-of-the-art advancements regarding this public health challenge and to identify immediate steps that the produce industry and regulators can take to prevent future outbreaks. The panel was also formed to determine what immediate steps can be taken for any future outbreaks to expedite the scientific investigation to prevent further cases and inform public health officials. The Blue-Ribbon Panel comprises 11 individuals with expertise in the biology of Cyclospora; the epidemiology of cyclosporiasis, including outbreak investigation; laboratory methods for identifying C. cayetanensis in human and food samples and the environment; and produce production. In addition,16 expert consultants from academia, federal and state public health agencies (including expert observers from the FDA, CDC, U.S. Department of Agriculture, and California Department of Public Health), and industry, including producers and professional trade association science experts. The collaboration and comprehensiveness of this effort was remarkable. Many hundreds of hours of meetings and conference calls took place to determine our findings and establish our recommendations.

This document, “Interim Report: Blue-Ribbon Panel on the Prevention of Cyclospora Outbreaks in the Food Supply,” summarizes the state-of-the art practices for the prevention of C. cayetanensis contamination of produce and priorities for research that will inform us as we strive to further reduce infection risk. Also, we make recommendations on how to more quickly identify and more effectively respond to produce-associated outbreaks when they occur. We greatly appreciate all the organizations represented on the panel and the expert consultants. The report does not, however, represent the official policy or recommendations of any other private, academic, trade association or federal or state government agency. Fresh Express has committed to continuing the Blue-Ribbon Panel process for as long as it can provide critical and actionable information to prevent and control Cyclospora outbreaks in the food supply.

Table: Summary of U.S. foodborne outbreaks of cyclosporiasis, 2000–2017
Year(s)* Month(s)* Jurisdiction(s)* No. of cases† Food vehicle and source, if identified‡
2000 May Georgia 19 Raspberries and/or blackberries (suspected)
2000 June Pennsylvania 54 Raspberries
2001 January–February Florida 39
2001 January New York City 3
2001–02 December–January Vermont 22 Raspberries (likely)
2002 April–May Massachusetts 8
2002 June New York 14
2004 February Texas 38
2004 February Illinois 57 Basil (likely)
2004 May Tennessee 12
2004 May–June Pennsylvania 96 Snow peas from Guatemala ⁂
2005 March–May Florida 582 ¶ Basil from Peru
2005 May South Carolina 6
2005 April Massachusetts 58
2005 May Massachusetts 16
2005 June Connecticut 30 Basil (suspected)
2006 June Minnesota 14
2006 June New York 20
2006 July Georgia 3
2008 March Wisconsin 4 Sugar snap peas (likely) ⁂
2008 July California 45 ¶ Raspberries and/or blackberries (likely)
2009 June District of Columbia 34
2011 June Florida 12
2011 July Georgia 88**
2012 June–July Texas 16
2013†† June Iowa, Nebraska, and neighboring states 162 Bagged salad mix from Mexico
2013†† June–July Texas 38 Cilantro from Mexico
2013 July Wisconsin 8 Berry salad (suspected)
2014 June Michigan 14
2014‡‡ June–July Texas 26 Cilantro from Mexico
2014 July South Carolina 13
2015 May–July Georgia, Texas, and Wisconsin 90 Cilantro from Mexico
2016 June–July Texas 6¶¶ Carrots or green cabbage (suspected)
2017 May Florida 6 Berries (suspected)
2017 May–July Texas 38*** Scallions (i.e., green onions)
2017 June Michigan 29
2017 June Tennessee 4†††
2017 June Connecticut 3
2017 July Florida 3‡‡‡

Metal is a risk in food, even in Australia

Mark Donaldson of the Wanneroo Times writes, a Currambine food outlet, which has now shut down, has been fined for a food safety breach after a customer bit into a piece of metal while eating a meal last year.

DS Business Venture, which ran Pastacup at Currambine Central, was due to stand trial in Joondalup Magistrates Court today but changed its plea to guilty.

No one from the business appeared in court to face the charge of “a person must not sell food that is unsuitable”.

The City of Joondalup prosecutor said a customer bought a three cheese ravioli from the store in May, 2017.

The complainant was eating a meal and bit into something hard, damaging a tooth.

Investigators found it was a rivet that had fallen off a cheese grater.

Magistrate Edward de Vries considered it a minor food safety case but said the customer “would have been in some pain biting into a metal rivet”.

He fined the business $3000 plus costs of another $3000.

The prosecutor conceded there was little chance of recovering the fine now the business had shut down.

RIP Malcolm Young

Today it is with deep heartfelt sadness that AC/DC has to announce the passing of Malcolm Young.

Malcolm, along with Angus, was the founder and creator of AC/DC.
With enormous dedication and commitment he was the driving force behind the band.

As a guitarist, songwriter and visionary he was a perfectionist and a unique man.

He always stuck to his guns and did and said exactly what he wanted.

He took great pride in all that he endeavored.

His loyalty to the fans was unsurpassed.

.As his brother it is hard to express in words what he has meant to me during my life, the bond we had was unique and very special.

He leaves behind an enormous legacy that will live on forever.

Malcolm, job well done.